Supreme Court: In a batch of criminal appeals arising from the conviction of a husband and his co-conspirators for the murder of his wife, a Division Bench of Dipankar Datta and Satish Chandra Sharma*, JJ., upheld the conviction of the husband (A1) and 2 co-accused (A4 and A5), holding that the prosecution had successfully established a complete chain of circumstantial evidence proving a premeditated conspiracy to murder the deceased. The Court held that the call detail records, CCTV footage, location data, recoveries made under Section 27, Evidence Act, 1872, and the unnatural conduct of the husband before and after the incident formed an unbroken chain pointing exclusively towards the guilt of the accused.
Observing that frequent telephonic conversations, by themselves, could not establish participation in a criminal conspiracy, the Court upheld the acquittal of the alleged co-conspirator (A2), holding that suspicion, however strong, could not substitute proof beyond reasonable doubt in the absence of evidence connecting her with the other accused or the execution of the offence. Consequently, the Court dismissed the appeals preferred by the convicted accused as well as the State’s appeal challenging A2’s acquittal.
“Marriage is often dubbed as one of the most significant decisions in the life of a person. The consequences of a marital discord could be drastic and at times, even fatal. The present case depicts an extreme scenario wherein two lives have met an irreversible fate as a consequence of their marital discord.”
Background
The present case arose from the murder of A1’s wife, who was allegedly killed pursuant to a criminal conspiracy hatched by her husband, A1, along with 4 assailants (A3 to A6). The prosecution alleged that the marriage, solemnised on 28 November 2012, had been strained due to A1’s alleged relationship with his neighbour, A2, which had led to frequent disputes between the spouses. On 27 July 2014, A1 took the deceased to Veranda Restaurant, Kanpur, for dinner as part of the conspiracy. After leaving the restaurant, A1 lodged a complaint alleging that unknown persons had intercepted their car, assaulted him, abducted his wife and fled with the vehicle. However, the investigation revealed that the alleged abduction had been staged and that A1 had conspired with A3 to A6, who had taken away the deceased in the car before murdering her.
Following the investigation, Crime No. 151 of 2014 was registered at Police Station Swaroop Nagar, Kanpur. The trial court convicted all 6 accused for offences punishable under Sections 302, 364, 201, 203 and 404 read with Section 120-B, Penal Code, 1860. On appeal, the Allahabad High Court, by its common judgment dated 29 November 2024, upheld the convictions of A1 and A3 to A6, relying on the call detail records, the evidence regarding the strained marital relationship, and A1’s conduct before and after the incident. However, it acquitted A2, holding that the evidence of frequent telephonic conversations with A1 was insufficient to establish either an illicit relationship or her involvement in the conspiracy. Aggrieved thereby, A1, A4 and A5 challenged their convictions before the Supreme Court, while the State of Uttar Pradesh appealed against A2’s acquittal.
Analysis
The Supreme Court held that the prosecution had successfully established a complete chain of circumstantial evidence which unequivocally pointed towards the guilt of A1, A4 and A5. The Court observed that the deceased was last seen with A1 at Veranda Restaurant and that the call detail records, CCTV footage, location data and the testimonies of the prosecution witnesses established a pre-existing conspiracy among the accused. The Court noted that A1 remained in constant touch with the co-conspirators immediately before the incident and that the accused failed to offer any plausible explanation for the incriminating circumstances within their exclusive knowledge, warranting an adverse inference. The Court further found A1’s conduct after the incident to be highly unnatural, observing that his false complaint of abduction, absence of injuries, abrupt departure from the hospital before medical examination and delayed approach to the police were consistent only with his involvement in the conspiracy.
The Court also relied upon the recoveries made at the instance of the accused under Section 27, Evidence Act, including the murder weapon, blood-stained articles, the deceased’s jewellery, clothes worn during the incident and the mobile phones used for communication. It held that the CCTV footage and invoices relating to the purchase of the knife further corroborated the prosecution case. Rejecting the contention regarding absence of motive, the Court observed that the evidence of the strained marital relationship, coupled with A1’s unusual association with A2, satisfactorily explained the motive behind the offence, while reiterating that motive assumes only a limited role where the chain of circumstantial evidence is otherwise complete. The Court also rejected the argument that Section 141 IPC, and not Section 34 IPC, was attracted, holding that A1’s active participation in the conspiracy, though behind the scenes, was sufficient to attract Section 34 IPC.
However, the Court upheld the acquittal of A2, holding that the evidence against her was confined to frequent telephonic conversations with A1. While such evidence could indicate the existence of a relationship, it was insufficient to establish her participation in the criminal conspiracy, particularly in the absence of any evidence connecting her with A3 to A6 or placing her within the chain of circumstances.
Decision
Finding no infirmity in the High Court’s appreciation of evidence, the Supreme Court affirmed the conviction of A1, A4 and A5, dismissed their appeals as well as the State’s appeal against A2’s acquittal, and directed the convicted appellants to surrender and serve their sentences in accordance with law.
Also Read: Strained Marriage Not Proof of Wife’s Murder: Madras HC | SCC Times
[Piyush Shyamdasani v. State of U.P., Criminal Appeal No(s). 3866 of 2025, decided on 20-7-2026]
*Judgment authored by: Justice Satish Chandra Sharma
